Epstein Secrets

(E) ORDER TO PRODUCE TAPE RECORDING Robert Y. Lewis affirms, under penalty of perjury, as follows: 1. I am an attorney admitted to practice law in the State of New York and a founding member of the law firm Freeman Lewis LLP, with offices at 228 East 45th Street, in Manhattan, New York. I submit this Affirmation in

ction by the Daily News of the recording. I attach the Rush declaration hereto as Ex. 3. 3 EFTA00728446 7. The Daily News then took an appeal to the Second Circuit. While the appeal was pending, however, the underlying civil suits by the three girls settled, leading to an automatic vacation of the district cou

of California. 2. Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein each reside in this District and are citizens of the State of New York. JURISDICTION AND VENUE 3. Plaintiff is a citizen of the State of California for purposes of diversity jurisdiction under 28 U.S.C. § 1332. 4.

al nature, and identification of Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity, especially factors 1-4, 7, and 10 (e.g., factors one and two: "whether the litigation invo

where the complaint stated, without any supporting facts, that the defendant "participates in a 'multina- tional insurance arrangement' present in the State of New York"); In re Ski Train Fire in Kaprun, Austria, 230 F.Supp.2d at 410-413 (granting motion to dismiss and denying jurisdictional discovery where compl

0 (hereinafter "Supp. Al-Wohai- bi Aff."). a. Status of the PIF In Filler v. Hanvit Bank, a case with facts very similar to those presented here, the Second Circuit reiterated Dole Food's requirement of direct ownership for instru- mentality status. Two defendants were commercial banks majority-owned by the Ko

of California. 2. Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein each reside in this District and are citizens of the State of New York. JURISDICTION AND VENUE 3. Plaintiff is a citizen of the State of California for purposes of diversity jurisdiction under 28 U.S.C. § 1332. 4.

al nature, and identification of Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity, especially factors 1-4, 7, and 10 (e.g., factors one and two: "whether the litigation invo

to Defendant's First Set of Discovery Requests to Plaintiff 1, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan &

en where the plaintiff can show no actual damages at all, a plaintiff who has otherwise shown defamation may recover at least nominal damages' and the Second Circuit also confirmed an award of punitive damages). Ms. Giuffre has been severely damaged by the defamation of the defendant, by calling her claims of se

Certain Depositions Designated By Plaintiff For Use At Trial I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan &

es statement contained in the report) will never be admissible unless there is a separate and independent hearsay exemptions for such statement. As the Second Circuit has clearly held: "It is well established that entries in a police report which result from the officer's own observations and knowledge may be adm

ly In Support of Her Objection to Unsealing Sealed Materials I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan &

rivacy interests of non- parties ... represents a legitimate basis for sealing judicial documents"). B. Effect of Previous Unsealing of Documents by Second Circuit Plaintiff claims that if a document is already public in another context, then it should be unsealed. She cites no law for this proposition, which

NT JPMORGAN CHASE BANK N.A. We, David Boies and Bradley Edwards, declare as follows: I. I, David Boies, am a member in good standing of the bar of the State of New York and am admitted to practice before this Court. I am the Chairman and a Managing Partner of Boies Schiller Flexner LLP ("BSF"). I make this declarat

ending final approval of this Settlement no later than two business days after filing the petition. JPMC shall withdraw any pending petition before the Second Circuit within two business days of the Effective Date. 1.5 "Class Member" or "Member of the Class" means a Person who falls within the definition of the